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Conyers Mold Legislation -

After reviewing the Conyers Toxic Mold Legislation, I make the following comments and suggestions.

In the area of those that have been trying to effect Legislation dealing with Insurance coverage and Mold, 21 of the 56 pages deal with that specific area. Over a third of the Legislation deals with those with insurance problems. If that meets their needs, I support them.

For those of us that have been infected by Toxic Mold, without insurance issues, due to illegal construction and corrupt government inspectors, we are not covered by this Legislation because there appears to be no waiving of the Statute of Limitations.

Throughout the Legislation, references are made about National Institute of Health studies. For those unaware, NIH has an ongoing study that is one-third done. The Chair of the study has stated in trials that "Toxic Mold is no big deal". So much for objective research from the NIH. The decision of what is to be "reported" seems to have already been determined.

There is great mention made of HUD. Sadly, HUD only insures those loans that are part of a HUD program. This comes from HUD itself. Also, HUD mad funds available to research Toxic Mold in how it relates to Asthma. These issues were told to me by HUD. They make grants of, in some Metro areas, of $850,000. This is not enough to cover a few mid priced homes that have to be razed and rebuilt due to Toxic Mold. These funds also have to, it appears, cover schools and public housing.

There is also mention of other issues of banks that are covered by FDIC and the such. Sadly, during the government licensed Bank construction inspections, many of the factors that contribute to Toxic Mold are missed or ignored. Many of these banks hire local government inspectors to do the banks inspections. This is a conflict of interest because the local inspector has to coverup the illegal construction they allow builders to perform. A decade ago I confirmed these facts that many covered FDIC banks use moonlighting local town inspectors. This answer was given by the FDIC in response to my investigation of billions of dollars in bad loans that led to many failed banks.

The part of the Legislation that is an insult, especially after having told the staff of Congressman Conyers, is Section 103, 3 ©. It calls for having State and local building inspectors establish the standards. It most cases, as I told the Congressman's staff, it is these people that are openly allowing the standards to be broken. To now give them full authority is a slap in the face to many of us that have been fighting this issue for far too many years. It would seem that the Congressman and his staff never bothered to listen or read the Public Record Documents I provided. He ignores the issue that has allowed Toxic Mold for the majority of us across the Country.

In the area of funding for Public buildings and schools, there is no dollar figure assigned. I have seen several studies that state that in the issue of schools Nationwide the cost would be as high as Seventy-Billion dollars. Where does that money come from? What services are going to be cut or what new taxes will be added to pay for it? The taxpayers will want an answer. I certainly would.

The Legislation calls for a mold inspection before the sale or lease of real property. Who is going to pay for it? Will this cost not be passed along to the buyer or renter? We already pay government inspectors for many of these services. Shouldn't the qualified and non-corrupt ones do this from the local taxes we already pay?

There is language that states conditions that facilitate indoor mold. What are those conditions? Does this include illegal construction and corrupt building inspectors? It needs to be defined. If the condition is corrupt building inspectors, where in the Legislation is the issue discussed? Where in the Legislation is there accountability for these corrupt officials?

In the area of Industry standards, I understand that Dr. Strauss has been doing testing on non-mold types of building materials. Perhaps there are others. Have they been consulted on these issues? If not, why?

In the area of tax credit for mold inspections and remediation, a top figure of $50,000 is given. In many cases, this is far too low. In many cases the cost would be hundreds of thousands of dollars. Where some are covered by insurance, what about those that are not? As an example, if an entire home and its contents were destroyed by Toxic Mold and the cost was 500 thousand dollars, the family would lose 450 thousand dollars if they were not covered by insurance because the mold came from illegal construction and government inspections. The Legislation does nothing to answer these issues. In most documented cases, Toxic Mold is usually a byproduct of illegal allowed construction by corrupt government inspectors. Why is there no accountability? By the way, what is the estimated National Tax Credit going to total and how is it going to be replaced in the Budget?

These are just some observations from pages 1 to 27. Most of the rest of the Legislation deals with those consumer groups that are fighting insurance companies. Most consumer groups are fighting the issue of Toxic Mold that is caused by illegal construction that is allowed by corrupt government inspectors. Those of us that are under this venue have no insurance coverage due to the corruption issue. The Legislation does nothing for us.

While this Legislation is a start, I consider it only a draft of what should be considered. There are too many areas that are ignored or left out. Before I can offer any form of support for pages 1 - 27, I need to see some major changes that will help and protect many of us across America. These pages do nothing to protect us from those that have caused or allowed the Toxic Mold conditions to exist. The Legislation relies upon many of those guilty for the proliferation of Toxic Mold for advice and consent.

Ken Moulton

508-771-6365

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